Gouldd means Bill, also known as William, Gouldd, individually, and as an officer of the Corporate Defendants. “Corporate Defendants” means Equinox International Corporation, Advanced Marketing Seminars, Inc., BG Management, Inc., their subsidiaries or affiliates, and all other corporations or business entities owned or controlled by any of the Corporate Defendants.
Assume and maintain full control of the Receivership Entities, by among other things, removing Gouldd and any other officer, employee, independent contractor, or agent of the Corporate Defendants, from control and management of the affairs of the Receivership Entities.
The Receiver shall maintain a repository of documents (including computer records) in the possession of Equinox and shall provide access to such documents to Gouldd as Gouldd reasonably finds necessary to protect his interests in legal proceedings.
Gouldd may petition the State of Maryland or the State of Hawaii to modify or waive this disclosure requirement.
Plaintiffs’ agreement to file a satisfaction of judgment with respect to Gouldd upon Defendants’ fulfillment of the provisions of this Subsection VIII.C is expressly premised upon the truthfulness, accuracy, and completeness of the sworn financial affidavits required by Subsection VIII.E of this Paragraph and related documents that were submitted to Plaintiffs reflecting Defendants’ financial condition.
As part of the settlement, the individual defendant, William Gouldd was barred permanently from engaging in any multi-level marketing operations.